Sherrie W Posted December 20, 2017 Posted December 20, 2017 A plan participant was able to write a check to his plan account on his own. Not deferral, not through payroll, etc. The plan does not allow for post tax contributions. How to correct?
Mike Preston Posted December 20, 2017 Posted December 20, 2017 Give the money back net of losses, if any.
Luke Bailey Posted December 20, 2017 Posted December 20, 2017 And as long as the return of the money occurs no later than the end of the second plan year after it went it, should qualify as self-correction of operational error under EPCRS. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
Mike Preston Posted December 21, 2017 Posted December 21, 2017 And even if not by the end of the second plan year it might very well be an insignificant error allowing self-correction under EPCRS.
Luke Bailey Posted December 21, 2017 Posted December 21, 2017 Right. Probably insignificant in any event, I agree. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
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